The tax exemption analysis of Sections 10(46) and 10(46A) does not imply that it is a fiscal concession; rather, it functions under a wider framework that is founded on controlled tax governance, with exemptions given on a conditional, selective, and by executive notice.

The central question is whether the court can extend time after the statutory 18-month period has expired, even after an arbitral award has been rendered.

The Section 230 arbitrage is not a design defect in either statute. SEBI’s framework assumes direct contractual transactions within its jurisdiction.